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Banking Stakeholder Group (BSG) – Summary of Meeting Minutes (23 June 2015)

Core Content

The Banking Stakeholder Group (BSG) convened on 23 June 2015 in London to discuss a range of topics related to regulatory developments, stress tests, consumer activities, and SME lending. The meeting aimed to align the BSG with the European Banking Authority (EBA) on key issues and to provide feedback on ongoing and upcoming regulatory initiatives.

Main Points and Key Information

1. Welcome and Approval of Agenda and Minutes

• The meeting commenced with a welcome from the BSG Chairperson.
• The minutes of the 27 April 2015 meeting and the agenda were approved.

2. BSG Update on Developments

• Consultation Papers: The BSG Chairperson reported on recent activities, including the submission of opinions on EBA/CP/2015/11 and JC/CP/2015/02. The EBA/CP/2015/09 was still unallocated.
• Volunteer Recruitment: A call for expression of interest was proposed to fill vacant positions in the BSG, particularly in the consumer category.
• Rules of Procedure (RoP) Amendments:
  • Amendments to Article 1.6 were approved, allowing for the appointment of new members if the existing list is exhausted or unsuitable.
  • Article 1.5 amendments were requested for further clarity and will be reviewed at the next meeting.
  • BSG members asked for clarification on the duration of BSG members' mandates.

3. Technical Working Groups' Activities

• The Working Group on Recovery, Resolution and Systemic Issues updated on ongoing consultation papers and highlighted the FSB's work on TLAC and cross-border resolution.
• The group discussed the similarities and differences between TLAC and MREL, and the challenges of implementing dynamic balance sheet assumptions.

4. Report on Proportionality

• The BSG Paper on proportionality was presented, emphasizing the need for a more balanced regulatory approach.
• Concerns were raised about the lack of discussion with supervisors in the 2014 stress tests and the need for more input.
• The EBA staff noted the difficulty in defining proportionality due to its multifaceted effects.
• The BSG Chairperson requested feedback by 2nd July to finalize the report.

5. BSG Opinion on Stress Tests

• The BSG Paper on the 2014 stress tests was presented, highlighting the need for more granularity in macroeconomic scenarios and a change in methodology using dynamic balance sheet assumptions.
• The report criticized the treatment of provisions and one-off impacts like mergers.
• The EBA Chairperson confirmed that the BSG inputs were considered in the BoS discussion and that a draft methodology would be circulated.
• Conduct risks were noted as a missing component in the stress tests, and the impact of IFRS 9 on provisions was highlighted.

6. EBA's General Developments

• The EBA Chairperson provided updates on regulatory products, including MREL, valuation methodologies, and securitisation guidelines.
• The 2016 Work Programme was introduced, with a call for BSG input on priorities.
• Concerns were raised about the lack of discussion with supervisors and the need for more transparency in data collection.

7. Consumer Activities and Trends

• The EBA updated on its consumer-related work, including the upcoming Consumer Trends Report 2015, which includes BSG input.
• Guidelines on product oversight, mortgages, and secure payments were highlighted.
• The BSG discussed issues such as dynamic currency conversion, lending rates for SMEs, and the role of the EBA in consumer protection.

8. SME Lending Discussion

• A BSG member presented on the importance of SMEs to the economy and the challenges they face in accessing finance.
• There was a call for better data collection and analysis to monitor capital flows to SMEs.
• The EBA will issue a Discussion Paper to gather evidence and opinions on SME lending issues.

9. Regulatory Products Under Development

• Draft RTS on Derivatives Valuation in Bail-in: The EBA staff presented this, noting the need for more data and methodological clarity.
• Corrigendum on RTS on Non-Delta Risk and CRD Remuneration: The EBA identified errors in the previously approved texts and proposed amendments without further consultation.

10. Action Items and Next Steps

• The BSG was asked to submit comments by 2nd July on the proportionality report.
• The EBA will publish the final report on its website and circulate it widely.
• A Discussion Paper on SME lending will be issued.
• The BSG was encouraged to propose topics for future meetings in October 2015.

Participants

• BSG Members: David T. Llewellyn (Chairperson), Andrea Resti (Vice-Chairperson), and other representatives from various sectors.
• Representatives from the EBA: Andrea Enria (Chairperson), Adam Farkas (Executive Director), and other EBA staff members.

Conclusion

The meeting underscored the BSG's active role in shaping regulatory discussions and the importance of collaboration between the EBA and the banking sector. Key areas of focus included stress tests, proportionality, SME lending, and consumer protection, with a call for more transparency, clarity, and stakeholder input.